Student Achievement And School Accountability Program

U. S. Department of Education Student Achievement and School Accountability Programs Monitoring Plan for the Enhanced Assessment Grants Program For Grants Funded with FY 2010 Funds (Updated – May 17, 2012) TABLE OF CONTENTS INTRODUCTION...... 3

PURPOSE OF THIS DOCUMENT...... 3

BACKGROUND ON THE ENHANCED ASSESSMENT GRANTS (EAG) PROGRAM ...3

BACKGROUND ON PROGRAM MONITORING...... 3

COMPONENTS OF MONITORING...... 3

AUGEMENTED DESK MONITORING PROCESS...... 5

MONITORING INDICATORS...... 5

MONITORING PROCESS...... 5

MONITORING REPORT...... 6

PROJECT RESPONSE...... 6

SASA FOLLOW-UP...... 6

RESOURCES...... 6

APPENDIX: PART I MONITORING INDICATORS FOR ENHANCED ASSESSMENT GRANTS: PROGRAM SPECIFIC INDICATORS AND PART II MONITORING INDICATORS FOR GENERAL EDGAR REQUIREMENTS

2 INTRODUCTION

A. Purpose of This Document

The purpose of this document is to describe in detail the purpose, rationale, and process used by the Student Achievement and School Accountability Programs (SASA) office in the U.S. Department of Education’s (ED) Office of Elementary and Secondary Education (OESE) in monitoring the use of discretionary grant funds under the Enhanced Assessment Instruments Grant program, also called the Enhanced Assessment Grants (EAG) Program.

B. Background on the Enhanced Assessment Grants (EAG) Program

Proficiency on State assessments required under section 1111(b)(3) of Title I, Part A of the Elementary and Secondary Education Act of 1965 (ESEA), as amended, is the primary indicator in the ESEA of student academic achievement and, hence, the primary measure of State success in meeting the goals of the ESEA. In view of the critical importance of these State assessments, the EAG Program provides discretionary grants to State educational agencies (SEAs) to help them enhance the quality of their assessment systems. These competitive awards, which are separate from the formula awards that all States receive from ED under section 6111 of the ESEA, are authorized by section 6112 of the ESEA. Since fiscal year (FY) 2002, eight cohorts of EAGs have been funded. More information on the EAG Program and its grantees is available on the EAG Program website at http://www.ed.gov/programs/eag.

C. Background on Program Monitoring

Monitoring is the regular and systematic examination of a grantee’s administration and implementation of a grant, a contract, or a cooperative agreement administered by ED. Monitoring the use of Federal funds has long been an essential function of ED. Monitoring formalizes the integral relationship between ED and the grantee. It emphasizes, first and foremost, accountability for using resources appropriately and wisely in the critical venture of educating and preparing our nation’s students. SASA has established a monitoring plan for each of its programs.

The purposes of monitoring the EAG Program are to (1) support the grantee in achieving program goals and objectives and ensure that project implementation conforms to the approved application; (2) ensure compliance with the requirements of the program’s authorizing statute (section 6112 of the ESEA) and other applicable statutes, with applicable regulations, such as the Education Department General Administrative Regulations (EDGAR)1, and any conditions placed on a grant; and (3) protect against waste, fraud and abuse. The monitoring plan for the EAG Program establishes procedures for achieving these purposes.

Through monitoring, ED gathers information about the grantee’s performance and needs. ED uses the information collected to design technical assistance initiatives and address weaknesses in project implementation. Thus, monitoring serves not only as a means for helping the grantee achieve compliant and high-quality implementation of educational programs, but also helps ED to be a better advisor and partner with the grantee in that effort.

COMPONENTS OF MONITORING

SASA staff will monitor the EAG to ensure that the project is being conducted in accordance with the approved application. The content of SASA’s monitoring is based on the specific statutory requirements in the ESEA for the EAG Program as well as other applicable statutes and regulations, such as EDGAR

1 The following legal authorities apply to Enhanced Assessment Grants: (a) the Education Department General Administrative Regulations (EDGAR) in 34 C.F.R. parts 74, 75, 77, 80, 81, 82, 84, 85, 86, 97, 98, and 99; and (b) the notice of final requirements published in the Federal Register on April 19, 2011 (76 FR 21986), including the statutory authorities identified therein.

3 provisions and OMB Cost Principles. Monitoring the grantee’s implementation means analyzing how the grantee has instituted the project design as described in the application to ensure compliance with the applicable statutes and regulations.

Monitoring of the EAG grantee includes three central components: (1) Performance Reporting, (2) On- going Desk Monitoring, (3) Quarterly Conference Calls, and (4) Augmented Desk Monitoring. The grantee is expected to submit performance reports and participate in on-going monitoring, and participate in an augmented desk monitoring. In addition, following the end of the project period, with the assistance of an expert panel, ED will review final products from the grant to evaluate the effectiveness of the EAG Program under the Government Performance and Results Act (GPRA).

Performance Reporting. Grantees must submit two kinds of reports, annual performance reports and a final performance report.

o Annual Performance Reports. A grantee receiving a multi-year award must submit annual performance reports that provide the most current performance and financial expenditure information, as specified by the Secretary in 34 CFR 75.590, 75.720, 80.40, and 80.41. These reports will be due to ED by August 15 each year of the grant until the final year. ED staff will contact the grantee during the year each report is due with more information on and instructions for the annual performance report. Information such as the following will be requested for the annual performance report: . Document of the degree to which the grantee has met the performance measures and the timelines outlined in its application; and . Documentation to address the interim performance measures for the program, specifically: (1) the forums through which the grantee plans to make available to SEA staff in non- participating states and to assessment researchers information on findings resulting from the Enhanced Assessment Grants, and (2) a list of proposed final products the grantee intends to produce under the grant; . Budget expenditures (for Federal grant funds and non-Federal funds); . Indirect cost information and program income, if applicable; and . Human subjects research certification.

o Final Performance Report. Within 90 days after the end of the project period, the grantee also must submit a final performance report. ED staff will contact the grantee during the final year of the grant with more information on and instructions for the final performance report. Information such as the following will be requested for the final performance report: . Documentation of the degree to which the performance measures and timelines outlined in the application have been met and the results of the project evaluation; . Descriptions of all significant research under the grant regarding assessment systems, assessments, related methodologies, and products or tools; . A list of all final products, publications and presentations produced as part of the grant. For each item in this list, provide enough information that individuals unfamiliar with your project will understand the context. For example,  For presentations, include the name of the presentation; the name of the conference or meeting, the date and its location; and presenters;  For papers, include a full citation for published papers and list the names of publications to which any other papers have been submitted; . Final products produced as part of the grant, (e.g., reports, papers (published and unpublished), presentations (Power Points, handouts, etc.), handbooks and manuals) . Budget expenditures (for Federal grant funds and non-Federal funds); and . Indirect cost information and program income, if applicable.

4 On-going Desk Monitoring. ED staff conducts on-going monitoring of the grantee’s implementation of its grant. This monitoring involves periodic informal conversations with the grantee, document reviews, tracking grantee drawdowns of funds, and checking grantee compliance with applicable requirements.

Quarterly Conference Calls. ED staff will contact the grantee on a regular basis to discuss progress on performance measures, including activities under the grant, and other aspects of grant administration.

Augmented Desk Monitoring. ED will conduct a more in-depth monitoring of the grantee, using the monitoring indicators outlined in the appendix of this document, to assess grantee performance and compliance with requirements. Augmented desk monitoring will occur during the second year of the project. The final sections of this document describe the procedures followed for this augmented desk monitoring.

Final Products Review with Expert Panel. With the final performance report, the grantee will submit the products developed under the grant. The grantee also will document both the states that participated in each grant and the dissemination activities. In addition to monitoring the implementation of EAGs, ED conducts an expert panel review of the final products of grants awarded under this program. ED uses the results of the expert panel review to rate ED’s success in addressing the four performance measures ED has developed for evaluating the effectiveness of the Enhanced Assessment Grants Program under GPRA: o The number of states that participate in Enhanced Assessment Grants projects funded by this competition, o The percentage of grantees that at least twice during the period of their grants make available to State educational agency staff in non-participating states and to assessment researchers information on findings resulting from the Enhanced Assessment Grants through presentations at national conferences, publications in refereed journals, or other products disseminated to the assessment community, o For each grant cycle and as determined by an expert panel, the percentage of Enhanced Assessment Grants that yield significant research, methodologies, products, or tools regarding assessment systems or assessments, and o For each grant cycle and as determined by an expert panel, the percentage of Enhanced Assessment Grants that yield significant research, methodologies, products, or tools specifically regarding accommodations and alternate assessments for students with disabilities and limited English proficient students.

AUGMENTED DESK MONITORING PROCESS

A. Monitoring Indicators

In its augmented desk monitoring, ED uses clear and consistent criteria, “monitoring indicators,” to determine the degree of implementation of grantee programs and activities. Monitoring indicators identify for the grantees and for ED staff the critical components of accountability by providing standards against which a grantee’s compliance and performance can be measured during monitoring. For example, the EAG monitoring indicators describe what is being monitored and provide the criteria for judging the quality of implementation (“acceptable evidence”). Monitoring indicators for the EAG Program include requirements applicable to discretionary grant programs in general as well as monitoring indicators specific to the EAG Program. The complete texts of monitoring indicators for the EAG Program are contained in the appendix to this document.

B. Monitoring Process

The grants project director will receive a letter regarding your augmented desk monitoring during the second year of the grant. This letter will ask the grant’s project director to submit evidence documenting how the monitoring indicators outlined in the appendices to this document are being addressed. The program specific monitoring indicators and monitoring indicators for general EDGAR requirements are

5 listed in the appendix. SASA staff will review this evidence and then conduct interviews with project staff via a conference call approximately one month after the evidence is submitted.

C. Monitoring Report

SASA staff will provide a report on the augmented desk monitoring to the grant’s project director within 35 business days of the conclusion of the conference call interview. The report may contain commendations, recommendations, and findings and required actions that together provide an analysis of the implementation of the approved EAG grant application.

D. Project Response and SASA Follow-up

Upon receipt of the report, the project director will have 30 business days to respond to any required actions. Once the project’s response is received by SASA, the monitor determines whether the response indicates that the project has taken steps to ensure full compliance in the identified areas. SASA’s Director then will send a letter to the project director approving or disapproving its proposed actions. If the project’s response is disapproved, SASA staff will work with the grantee to ensure that areas of non- compliance are addressed.

As needed, SASA staff will follow-up on issues identified in augmented desk monitoring during the remainder of the project period. This follow-up may include providing additional technical assistance to the grantee and more frequent communication and monitoring of the grantee by ED staff. It also may involve placing conditions on grants and other actions, as appropriate, if compliance issues remain unresolved or performance problems persist.

RESOURCES

All grantees must administer their grants to achieve the scope and objectives of the project outlined in the application and so that they comply with all other applicable requirements, whether or not they are selected for augmented desk monitoring. The following list provides several resources that are available to support grantees in effectively administering grants:

 Enhanced Assessment Grant (EAG) website: http://www.ed.gov/programs/eag

 Resources page of the EAG website: http://www.ed.gov/programs/eag/resources.html

 Upcoming training on Discretionary Grant Administration for EAG grantees (program staff will be contacting grantees regarding availability)

 Student Achievement and School Accountability Programs Monitoring Plan for the Enhanced Assessment Grants Program: See Resources page of the EAG website

 EDGAR: www.ed.gov/policy/fund/reg/edgarReg/edgar.html. The following EDGAR requirements apply to the EAGs: 34 CFR parts 74, 75, 77, 80, 81, 82, 84, 85, 86, 97, 98, and 99

 OMB Circulars: See Resources page of the EAG website

 Online Grantee Training for ED Discretionary Grants: http://e-grants.ed.gov/training/index.htm

Grant making at ED, a non-technical summary of ED's discretionary grant process and the laws and regulations that govern it: http://www2.ed.gov/fund/grant/about/grantmaking/index.html

 Online training for G5 system, ED’s electronic system for grants management and payments: www.g5.gov

6  ED Recovery Act Technical Assistance Web Conferences (technical assistance on a range of topics related to administering discretionary and formula grants): See Resources page of the SASA website.

7 APPENDIX

PART 1: PROGRAM SPECIFIC MONITORING INDICATORS FOR ENHANCED ASSESSMENT GRANTS PROGRAM

Monitoring indicator Acceptable documented evidence Acceptable interview evidence EAG 1.1: Grantee enhances the quality of  Documentation of progress on project  Staff explains how activities under the assessment instruments and systems used by activities consistent with original proposal. grant will yield significant research, states for measuring the achievement of all  Documentation of research products from methodologies, products, or tools students, in accordance with its application. activities under the grant, and/or regarding assessment systems or documentation of progress toward assessments; and/or regarding ESEA Section 6112(a) completing such products. accommodations and alternate assessments  Documentation that products from for students with disabilities and limited activities under the grant will yield English proficient students. significant research, methodologies, products, or tools regarding assessment systems or assessments; and/or regarding accommodations and alternate assessments for students with disabilities and limited English proficient students.

Monitoring indicator Acceptable documented evidence Acceptable interview evidence EAG 1.2: Grantee collaborates with  Contracts with other collaborating entities.  Staff explains the roles of all participants institutions of higher education, other research  Minutes from management meetings, and their involvement in grant activities. institutions, or other organizations to improve records of communications with members the quality, validity, and reliability of State of the grant consortium, and/or academic assessments beyond the statutory documentation outlining the roles of all requirements. participants in grant activities.  If applicable, binding agreement between ESEA Section 6112(a)(1), EDGAR 75.128 all SEA members of the consortium that (1) details the activities that each member of the consortium plans to perform; and (2) binds each member of the consortium to every statement and assurance made by the applicant in its application.

5 Monitoring indicator Acceptable documented evidence Acceptable interview evidence EAG 1.3: Grantee completes major project  Documentation of progress consistent with  Staff explains progress to date as well as activities consistent with original timeline and goals, timelines, benchmarks and outcome any timeline adjustments needed, the within the contract period. measures in application. reason such adjustments are needed and the impact on final results. ESEA Section 6112(a), EDGAR 80.40

Monitoring indicator Acceptable documented evidence Acceptable interview evidence EAG 1.4: Project activities continue to  Documentation of how the grantee is  Staff explains how the grantee is conform to the regulatory absolute priority for addressing the criteria from the regulatory addressing the regulatory absolute this award (English Language Proficiency absolute priority for the grant: priority. Assessment Systems). Absolute Priority 5—English Language ESEA Section 6112, ESEA Section 9302 Proficiency Assessment System. To meet this priority, an applicant must propose a comprehensive plan to develop an English language proficiency assessment system that is valid, reliable, and fair for its intended purpose. Such a plan must include the following features:

(a) Design. The assessment system must--

(1) Be designed for implementation in multiple States; (2) Be based on a common definition of English learner adopted by the applicant State and, if the applicant applies as part of a consortium, adopted and held in common by all States in the consortium, where common with respect to the definition of “English learner” means identical for purposes of the diagnostic (e.g., screener or placement) assessments and associated achievement standards used to classify students as English

6 Monitoring indicator Acceptable documented evidence Acceptable interview evidence learners as well as the summative assessments and associated achievement standards used to exit students from English learner status; (3) At a minimum, include diagnostic (e.g., screener or placement) and summative assessments; (4) Measure students’ English proficiency against a set of English language proficiency standards held by the applicant State and, if the applicant applies as part of a consortium, held in common by all States in the consortium; (5) Measure students’ English proficiency against a set of English language proficiency standards that correspond to a common set of college- and career-ready standards (as defined in this notice) in English language arts and mathematics, are rigorous, are developed with broad stakeholder involvement, are vetted with experts and practitioners, and for which external evaluations have documented rigor and correspondence with a common set of college- and career-ready standards in English language arts and mathematics; (6) Cover the full range of the English language proficiency standards across the four language domains of reading, writing, speaking, and listening, as required by section 3113(b)(2) of the ESEA; (7) Ensure that the measures of students’ English proficiency consider

7 Monitoring indicator Acceptable documented evidence Acceptable interview evidence the students’ control over the linguistic components of language (e.g., phonology, syntax, morphology); (8) Produce results that indicate whether individual students have attained the English proficiency necessary to participate fully in academic instruction in English and meet or exceed college- and career- ready standards; (9) Provide at least an annual measure of English proficiency and student progress in learning English for English learners in kindergarten through grade 12 in each of the four language domains of reading, writing, speaking, and listening; (10) Assess all English learners, including English learners who are also students with disabilities and students with limited or no formal education, except for English learners with the most significant cognitive disabilities who are eligible to participate in alternate assessments based on alternate academic achievement standards in accordance with 34 CFR 200.6(a)(2); and (11) Be accessible to all English learners, including by providing appropriate accommodations for English learners with disabilities, except for English learners with the most significant cognitive disabilities who are eligible to participate in alternate assessments based on alternate academic achievement

8 Monitoring indicator Acceptable documented evidence Acceptable interview evidence standards in accordance with 34 CFR 200.6(a)(2)

(b) Technical quality. The assessment system must measure students’ English proficiency in ways that--

(1) Are consistent with nationally recognized professional and technical standards; and (2) As appropriate, elicit complex student demonstrations of comprehension and production of academic English (e.g., performance tasks, selected responses, brief or extended constructed responses).

(c) Data. The assessment system must produce data that--

(1) Include student attainment of English proficiency and student progress in learning English (including data disaggregated by English learner subgroups such as English learners by years in a language instruction educational program; English learners whose formal education has been interrupted; students who were formerly English learners by years out of the language instruction educational program; English learners by level of English proficiency, such as those who initially scored proficient on the English language proficiency assessment; English learners by disability status; and English learners

9 Monitoring indicator Acceptable documented evidence Acceptable interview evidence

by native language); (2) Provide a valid and reliable measure of students’ abilities in each of the four language domains (reading, writing, speaking, and listening) and a comprehensive English proficiency score based on all four domains, with each language domain score making a significant contribution to the comprehensive ELP score, at each proficiency level; and (3) Can be used for the--(i) Identification of students as English learners; (ii) Decisions about whether a student should exit from English language instruction educational programs; (iii) Determinations of school, local educational agency, and State effectiveness for the purposes of accountability under Title I and Title III of the ESEA; (4) Can be used, as appropriate, as one of multiple measures, to inform-- (i) Evaluations of individual principals and teachers in order to determine their effectiveness; (ii) Determinations of principal and teacher professional development and support needs; and(iii) Strategies to improve teaching, learning, and language instruction education programs.

(d) Compatibility. The assessment system must use compatible approaches to technology,

assessment administration, scoring, reporting, and other factors that facilitate the coherent inclusion of the assessments within States’ student assessment systems.

(e) Students with the most significant cognitive disabilities. The comprehensive plan to develop an English language proficiency assessment system must include the strategies the applicant State and, if the applicant is part of a consortium, all States in the consortium, plans to use to assess the English proficiency of English learners with the most significant cognitive disabilities who are eligible to participate in alternate assessments based on alternate academic achievement standards in accordance with 34 CFR 200.6(a)(2) in lieu of including those students in the operational administration of the assessments developed for other English learners under a grant from this competition.

Monitoring indicator Acceptable documented evidence Acceptable interview evidence EAG 1.5: Grantee complies with program  Documentation of how the grantee is  Staff explains how the grantee is requirements of the grant as set in the Notice addressing program requirements to do addressing the regulatory requirements. Inviting Applications (6 FR 21978) for the the following: grant. (a) Evaluate the validity, reliability, and ESEA Section 6112, ESEA Section 9302 fairness of any assessments or other assessment-related instruments developed under a grant from this competition, and make available documentation of evaluations of technical quality through formal mechanisms (e.g., peer-reviewed

journals) and informal mechanisms (e.g., newsletters), both in print and electronically;

(b) Actively participate in any applicable technical assistance activities conducted or facilitated by the Department or its designees, coordinate with the RTTA program in the development of assessments under this program, and participate in other activities as determined by the Department;

(c) Develop a strategy to make student- level data that result from any assessments or other assessment- related instruments developed under a grant from this competition available on an ongoing basis for research, including for prospective linking, validity, and program improvement studies;2

(d) Ensure that any assessments or other assessment-related instruments developed under a grant from this competition will be operational (ready for large-scale administration) at the end of the project period;

(e) Ensure that funds awarded under the EAG program are not used to support the development of standards, such as

2 Eligible applicants awarded a grant under this program must comply with the Family Educational Rights and Privacy Act (FERPA) and 34 CFR Part 99, as well as State and local requirements regarding privacy.

under the English language proficiency assessment system priority or any other priority.

(f) Maximize the interoperability of any assessments and other assessment- related instruments developed with funds from this competition across technology platforms and the ability for States to move their assessments from one technology platform to another by doing the following, as applicable, for any assessments developed with funds from this competition by-- (1) Developing all assessment items in accordance with an industry- recognized open-licensed interoperability standard that is approved by the Department during the grant period, without non-standard extensions or additions; and (2) Producing all student-level data in a manner consistent with an industry-recognized open-licensed interoperability standard that is approved by the Department during the grant period;

(g) Unless otherwise protected by law or agreement as proprietary information, make any assessment content (i.e., assessments and assessment items) and other assessment-related instruments developed with funds from this

competition freely available to States, technology platform providers, and others that request it for purposes of administering assessments, provided that those parties receiving assessment content comply with consortium or State requirements for test or item security; and

(h) For any assessments and other assessment-related instruments developed with funds from this competition, use technology to the maximum extent appropriate to develop, administer, and score the assessments and report results.

Monitoring indicator Acceptable documented evidence Acceptable interview evidence EAG 1.6: Grantee includes dissemination  Plan for utilizing and disseminating  Staff describes how findings will be used activities as integral component of the project. findings within the grant consortium and to and disseminated by members of the grant state educational agencies (SEAs) beyond consortium. ESEA Section 6112(a) the consortium.  Staff describes how findings will be used  Documentation of actions taken by grantee by state educational agencies beyond the to make information on findings resulting grant consortium. from the EAG available to SEA staff in  Staff describes issues of ownership among non-participating states and to assessment members of the consortium, including any researchers (e.g., through presentations at copyrights anticipated under the grant. national conferences, publications in refereed journals, or other products disseminated to the assessment community).  Evidence that dissemination activities are targeted to appropriate audiences and include clearly stated descriptions of work in progress or final products.

14 Monitoring indicator Acceptable documented evidence Acceptable interview evidence EAG 1.7: Grantee submits a complete annual  Annual report with all required  Staff demonstrates that it understands the report describing its activities and the result of components submitted by due date. format and timeline for submitting an those activities under the grant by the due date annual performance reports to ED. established by ED.

ESEA Section 6112(c); EDGAR 75.590; 75.720; 80.40; 80.41

PART 2: MONITORING INDICATORS FOR GENERAL EDGAR REQUIREMENTS

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.1: Grantee directly administers or supervises  Grant application.  Staff describes how the grantee the administration of the project.  Agendas and meeting notes from meetings administers the project. with collaborating organizations, if  Staff describes how the grantee supervises EDGAR 75.701 applicable. the administration of the project, such as  Communications with partner through interactions with staff in partner organizations, if applicable. organizations, if applicable.

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.2: Grantee is aware of and uses the  Contracts and procurement records.  Staff is aware of these requirements and appropriate procurement standards (i.e., State  Evidence that grantee has followed state explains how services are obtained from follows the same policies and procedures for procurement practices. other organizations. this program that it uses for procurements from  Monitor does not observe subgranting its non-Federal funds), and grantee does not activities. make a subgrant with grant funds.

EDGAR 75.708; 80.36

15 Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.3: Grantee monitors grant supported  The grantee maintains a contract  Staff describes how the grantee monitors activities to assure compliance with applicable administration system which ensures that contracts under the grant. Federal requirements, that performance goals contractors perform in accordance with the  Staff discusses plan for monitoring are being achieved, and that grantee terms, conditions, and specifications of contractor for performance and compliance monitoring covers each program, function or their contracts or purchase orders. as well as documentation of regular activity.  The grantee maintains a contract monitoring of contractor(s) by grantee. administration system for monitoring EDGAR 80.36(a); 80.40 contractor performance and for ensuring all contracts under the grant are implemented in compliance with applicable requirements.  Documentation of implementation of plan for monitoring contractor performance.

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.4: Grantee keeps the required records related  Documentation of established procedures  Staff is familiar with such records. to grant funds and meets requirements for for tracking time and attendance for  Staff explains how such records are financial reporting. personnel and related records; maintained and used.  Documentation of established procedures  Staff is aware of what materials would be EDGAR 75.730; 80.20(a); 80.41 for in-kind contributions outlined in the needed for an audit by ED, the State, or approved application and related records; other relevant entity.  Records of how the grantee has used the  Staff meets all applicable reporting funds (e.g., by category outlined in the requirements. approved application) and tracked in-kind contributions;  Documentation that the time commitments of project staff are consistent with the approved application;  For contractual expenses: monthly project reports aligned with invoices for services and/or materials related to this grant received by the grantee, for each such invoice, documentation of appropriate supporting detail for expenses, such as personnel costs (e.g., personnel

16 Monitoring indicator Acceptable documented evidence Acceptable interview evidence involved and time worked), fringe benefits (e.g., how they are calculated), travel (e.g., justification of purpose of trips, where, who went, per diem rates, etc.), equipment and supplies, subcontracts and temporary labor (e.g., detail similar to that for contracts), indirect costs (e.g., how they are calculated), and other detail as needed to enable the grantee to ensure that expenses are allowable, allocable and reasonable charges for activities under the grant;  For any incentives provided for participation under the grant, documentation that the individuals earned the incentives provided, and that the amount spent on incentives matches the amount of incentives provided;  Total project cost;  Other records to facilitate an effective audit; and  Copies of any completed audits.

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.5: Grantee uses fiscal control and fund  Records showing timely and accurate  Staff describes the following: accounting procedures that ensure proper disbursement and accounting practices.  accounting procedures used; disbursement of and accounting for Federal  Records of draw-downs and disbursements  how records are maintained; and funds, and has in place and follows standards show a minimal amount of time elapsing  how timely disbursements are made. for financial management systems. (i.e., three days or fewer) between the  Staff is familiar with standards for draw-downs and disbursements. financial management systems. EDGAR 75.702; 80.20; 80.21; 80.22  Records showing that grantee has made payments only for actual expenditures (i.e., work performed).  Documentation of process for achieving effective control over and accountability for all funds, property, and other assets.

17 Monitoring indicator Acceptable documented evidence Acceptable interview evidence  Documentation of procedures for safeguarding all assets, and assurances that assets are used solely for authorized purposes.  Documentation of financial management systems that meet required standards, including maintaining:  records that identify the source and application of Federal funds (from drawdown to disbursement);  records that show a comparison of outlay with budgeted amounts for each award;  accounting records including cost accounting records that are supported by source documentation;  written procedures for determining the reasonableness, allocability, and allowability of costs; and  written procedures for minimizing the time between drawdowns and disbursements.

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.6: Grantee follows the general cost  Budget does not include construction or  Staff describes costs for which the funds principles specified in EDGAR 74.27 and acquisition costs (such as acquisition of may be used. 80.22 as applicable, and uses funds only for real property).  Staff demonstrates understanding of and allowable costs. (See also applicable OMB  The costs charged by the project are uses applicable cost principles. circulars). reasonable and necessary, based on the approved application, and are allocable to EDGAR 74.27; 75.263; 75.530 – 75.533; the program 80.22

18 Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.7: Grantee does not use its grant funds to  Documentation of staff FTE amounts and  Staff describes how personnel costs are pay a project staff member for time or work for personnel costs as stated in the budget in funded. which that staff member is compensated from the approved application.  Staff explains how record is kept of each some other source of funds.  Expenditure reports for personnel costs employee’s total FTE, especially when an that align with amounts and personnel employee is budgeted to work on the EDGAR 75.519; OMB Circular A-87, costs stated in budget. funded project for only a portion of his/her Attachment B, paragraph 8(h); OMB Circular  Time distribution records personnel who time. A-122, Attachment B, paragraph 8(m); OMB work less than full time on the program Circular A-21, Attachment, paragraph J(10)(b) (e.g., FTE spent on grant project and FTE devote to other projects for grant staff).

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.8: As applicable, the grantee uses an  Expenditure reports of amount of indirect  Staff explains how this requirement is met. approved and applicable indirect cost rate. costs charged to project and the base to  Appropriate staff knows what the which they were applied that demonstrate applicable indirect cost rate is. EDGAR 75.560 – 75.564 that indirect costs are being charged correctly.  Indirect Cost Agreement(s) applicable to the project period.

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.9: Grantee uses grant funds only for  Receipts and/or records of funds used for  Staff explains how this requirement is met. obligations it makes during the grant period. obligations that list what funds were used for, the amount used, and when obligation EDGAR 75.703 was made.

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.10: When making any revisions from the  Documentation of ED approval for  Staff is aware that changes that ED must approved application, the grantee follows changes in implementation from the approve. requirements, including requesting prior approved application that require ED  Staff is aware that the scope and objectives

19 Monitoring indicator Acceptable documented evidence Acceptable interview evidence approval as appropriate, under EDGAR. approval (e.g., changes that require prior of the grant cannot be changed. approval under EDGAR or applicable  Staff can explain revisions made from EDGAR 75.264; 75.517; 80.30 OMB Circulars (A-21, A-87 and A-122)). approved application, such as revisions to  Documentation that all key personnel the amounts in the budget categories positions that were vacant at the time of outlined in the application and transfer or the award (as noted on the Grant Award contracting out of any work. Notification) were filled in a timely manner and that change was approved by ED.  Unless described in the application and funded in the approved awards, documentation that the transfer or contracting out of any work under an award (does not apply to the purchase of supplies, material, equipment, or general support services) was approved by ED.  Documentation of ED approval for any absence for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.  Necessary documentation of other changes (e.g., first-time extension of the project period not exceeding 12 months).  Documentation that the grantee has submitted to ED written requests for approval of any changes to the membership of the consortium and received ED approval before implementing any changes addressed in the request.

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.11: Grantee has requested and received ED  As applicable, written request for changes  Staff describes any changes to the approval of any changes to the membership of to the membership of the consortium and membership of the consortium. the consortium. documentation of ED approval.

EDGAR 75.128

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.12: Grantee complies with the requirements  For projects involving non-exempt human  Staff explains how participant records are for student rights in research, experimental subjects research, valid human subjects stored and kept confidential. programs, and testing. research approval documents.

EDGAR 75.740(b); and Part 98

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.13: Grantee complies with all conditions  As applicable, documentation of how the  Staff explains how conditions attached to attached to the grant. grantee has addressed and/or is addressing the grant have been and/or are being all conditions attached to the grant. addressed. EDGAR 75.234; 75.235

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.14: Grantee complies with the requirements  Permission/consent forms from  Staff explains how participant records are for the protection of privacy of parents and participants and/or parents where stored and kept confidential. students under the Family Educational Rights applicable. and Privacy Act (FERPA).

EDGAR 75.740(a); and Part 99; Section 444 of the General Education Provisions Act (GEPA)

21 Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.15: Grantee follows the regulations  If applicable, required documentation for  Staff is aware of whether program income governing program income related to projects how program income is handled. is being earned. If program income is financed in whole or in part with Federal earned, staff is aware of how it is handled. funds.

EDGAR 80.25

Monitoring indicator Acceptable documented evidence Acceptable interview evidence 2.16: Grantee complies with the regulations  Inventory of property and equipment  Staff explains whether property and governing management and disposition of purchased with grant funds that is equipment have been or will be purchased property and equipment whose cost was consistent with all applicable regulations. under the grant. charged to a project supported by a Federal  Staff is aware of these requirements and award. discusses how they are met.

EDGAR 80.31-80.33